Can a federal court enjoin a state action for medical malpractice?

On appeal, this court held that the "in aid of jurisdiction" exception did not authorize the federal court to enjoin the state malpractice suit. We reiterated that the exception "is generally reserved for state court actions in rem, because the state court's exercise of jurisdiction 'necessarily impairs, and may, defeat,' the federal court's jurisdiction over the res." Id. at 137-38 (quoting Kline v. Burke Constr. Co., 260 U.S. 226, 229 (1922)). Because "an in personam action involves a controversy over liability rather than over possession of a thing[,] . . . an in personam action generally does not tend to impair or defeat the jurisdiction of the court in which a prior action for the same cause is pending." Id. at 138 (internal quotation marks omitted).